Chapter 457: Three Applications

He Xiufen took a cab over, from Zhongshan Road to the east side of the city, about twenty minutes. She stopped at the bottom of the courthouse steps, unzipped the dark blue document pouch, pulled out three sheets to check the order, then slid them back exactly as they'd been. The pouch's corners were worn pale. Inside, three pages, each clipped separately.

"The order of the three can't be reversed," she said. "They read from the top. The first one should be the one about calling people in."

She'd arrived ten minutes early and stood on the steps watching the bailiff slide open the iron barrier at the entrance. The two of them went through security one after the other. When the conveyor belt stopped, He Xiufen reached in, took the pouch back, and flipped through it against the light, checking for creased corners from the machine.

"A crease means wasted work."

Seven or eight people sat on the chairs on the first floor. One man clutched a woven sack, someone else had a medical record book rolled into a tube in their fist. They edged past the crowd, up the stairs. The sign at the landing was small, the lettering faint—it said the criminal division was on the third floor. Neither of them paused.

On the third floor, He Xiufen set the pouch on the windowsill, pulled out one sheet to check the signature block—her own name, defense counsel, dated September 13th. She looked it over, tucked it back, then knocked.

Inside, the court clerk sat at the far desk, a stack of files on top, white labels stuck to the spines. When they came in, she set down her pen first.

"Director He."

"Three applications." He Xiufen laid the papers out on the counter, pushing them apart one by one into three separate piles. "Please write a receipt slip."

The clerk flipped through them one at a time, slowly, then looked up. "Application to have witnesses testify in court."

"Three. Lu Jibai, Pang Chunlai, Han Chongli."

"Under Han Chongli's name there's more writing." She read it flatly. "That year Hengzheng was the party that submitted the re-test samples. The submission was arranged by the firm, and Han Chongli was the person in charge of the firm at the time."

"That sentence has to be clear. If it's not clear, they'll ask why he's being called."

"Have you been in touch with these three?"

"Two said they'd come on their own," He Xiufen said. "The third one, the court has to call."

"Pang Chunlai, at his age." The clerk pressed the paper flat. "One bump in the road might do him in."

"His legs are bad and he's hard of hearing." He Xiufen said. "It's in the application—we recommend the court send a car. He wants to come. If he doesn't, the car comes back empty."

The clerk made a sound of acknowledgment, smoothed down the paper's corner with her knuckle, noted the point, and turned to the second page.

"Application for forensic examination of the Qingyuan Testing Center seal and Cen Shouye's signature on the original re-test documents." She looked up at this point. "Where's the original?"

"In the main file for that case at Chengbei District Court. On July 20th, the Intermediate Court borrowed the entire file, sealed it in a bag, two names on the seal, and it hasn't been opened since."

"The file is with us now."

"I know. That's why this is an application, not a notice." He Xiufen said. "If it goes out, send the whole file. Don't open it. Once opened, that document's worth nothing."

The clerk's pen pressed down on the paper, noted that too, and turned to the third page. Halfway through, she read the title aloud. "Request for the court to obtain from the Chengnan District People's Procuratorate the single page of sample handover form preserved in that year's procuratorate file, attached after the test report."

"One page."

"A photocopy's acceptable?"

"A photocopy's acceptable." He Xiufen said. "We don't know where the original is, only that they still have a copy on file. If we go ask for it ourselves, they won't give it to us. The court has to send a letter."

"The letter comes from us," the clerk said. "When it comes back, I can't say."

"If it doesn't come back, we'd like word either way."

The three pages were squared up and clipped with a binder clip. The clerk pulled a receipt slip from the drawer and wrote it out line by line: the date, who submitted, what was submitted, how many pages each, signed at the bottom, the seal stamped over the name. She pushed it to the middle of the counter when she'd finished.

He Xiufen held it up to the window, looked it over, and set it down. "The defense has a few more items," she said. "The original of the July 1st interview record, three pages; one disc; and a notebook—to be shown, not submitted. All originals. They can't be handed in at a window like this. At the meeting the court's holding before trial, I'll bring them up. Tell me the date when it's set."

"Call ahead that day and I'll come down to meet you," the clerk said. "Original documents need to be registered. Someone has to witness it."

"Fine."

The whole time, she'd stood by the window without speaking. When the clerk filed the papers, she glanced at her. "This one is?"

"The petitioner. Also a close relative." He Xiufen said. "She's listening."

"Then sign here too."

The paper was turned around, a finger pointing to the bottom line. She picked up the pen, wrote her name, and put the pen back in the holder, tip facing inward.

By the time they went down, half the chairs were empty. A man in his fifties came over from the filing window, startled at the sight of He Xiufen, then smiled. "Director He, you still appear in court."

"I do."

"I'd heard you retired."

"Half retired." He Xiufen said. "One case left."

"So when do you—"

"When this one's done." She said. "Your matter can wait. Don't go shouting at the window."

The man nodded and headed out the door. The steps were bleached white in the sun, a row of electric scooters at the bottom, light glaring off the seats. The two of them stood there for a moment.

"So that's it?" she asked.

"That's not it." He Xiufen shifted the pouch to her other hand. "The papers go in. After that, it's out of our hands. Whether they're approved, when they're approved—that's all theirs."

"So what do we have?"

"The originals we're taking to court that day. And our mouths." He Xiufen glanced at her watch. "Come on, let's go back and have noodles. I'll show you the draft this afternoon."

Lunch service had just ended; the stove downstairs was still hot. The second-floor windows were open, cooking oil smoke and scallion scent climbing layer by layer. He Xiufen made herself a bowl of noodles at the old wooden chair by the window, two pairs of chopsticks. She pushed the bowl over. "Eat first. You can look after."

At three o'clock, she spread the three draft applications on the table. The edges showed corrections, the changed characters squeezed between lines, one size smaller than the body text.

"The witness one." He Xiufen slid over the top sheet.

She read line by line. Lu Jibai, address, phone. Pang Chunlai, address, phone, with a note added after: "Elderly, limited mobility, the court is advised to provide transport." Then the next line.

Han Chongli. Neatly written, just as it always was.

She pressed her thumb to it, leaving a white crease at the paper's edge.

"Will he come?"

"If the court notifies him, he has to come." He Xiufen said. "He's not a relative of the defendant. He can't refuse."

"What if he doesn't?"

"When a witness's testimony has a major bearing on conviction, and both sides dispute it, that witness should appear. If they're notified and don't show, the court can compel attendance." He Xiufen lifted her tea mug and took a sip. "That clause reads nicely on paper. It's less useful in practice. But he can't afford the embarrassment. He'll show up dressed like he's going to a meeting."

"Last time, in the Hengzheng lobby, he talked for nearly fifty minutes."

"This time he won't be the only one doing the talking."

"The first name."

"The court will notify him," He Xiufen said. "And don't you go telling him what he'll be asked in court. If he hears it from your mouth, what he says up there won't be his own anymore."

She pushed the noodle bowl aside. "I won't say anything."

"Good." He Xiufen lined the chopsticks up. "Your father had the same rule: a lawyer doesn't rehearse a witness's testimony for him."

Li Huilan was writing a receipt at her own desk. Halfway through, she broke in. "The second application's harder than the first."

"How so?"

"Handwriting needs comparison samples." Li Huilan set her pen down. "The appraiser needs exemplars, and the exemplars have to come from the right hands. Qingyuan's reports from those years, their seal impressions on file, and his signatures in other cases."

"The court will retrieve them." He Xiufen said. "That Chengbei District Court file has his complaint. Whatever the appraiser needs, the court retrieves, we don't hand anything over."

"The Cen family—" she started.

"We don't hand anything over." He Xiufen was blunt. "If his daughter tries to submit something, you stop her too. Unless the court asks, nothing gets sent on our own."

She looked down at the third application. The shortest one: a request for the court to obtain that single page from the Chengnan District People's Procuratorate, with one line added at the bottom—please also state where this page currently resides.

"Why is this one the shortest?"

"Because it asks for the least." He Xiufen said. "One page, one storage location, one sentence."

"What if they can't find it either?"

"Then it's truly gone." He Xiufen said. "Lose one thing, the rest remains. You submitted three today. Maybe two come back. Maybe one. Don't stare at that window waiting."

"I won't."

"Then go sort out what we're bringing, list every item on paper," He Xiufen said. "What gets taken on which day, write it clearly. Don't be digging through your bag at the last minute."

"Write it on paper?"

"Write it in a notebook." He Xiufen said. "Your father did the same. The night before trial, he'd write down the three questions he needed to ask."

The inner office door was shut, a thin line of light under the crack, the sound of a chair scraping occasionally from within. He Xiufen glanced toward the door, gathered the three drafts, and pressed them into her drawer.

"This one doesn't get shown to him?" she asked.

"He's a witness." He Xiufen said. "A witness who doesn't know what he'll be asked speaks more cleanly."

By five o'clock, she was alone in the outer office. Downstairs, someone was clearing tables, bowls and plates clinking together—once, then again. She opened her notebook to a fresh page.

At the top, following her father's format, she wrote the date and time first: September 13th, 17:00.

Second line: Three applications submitted, one receipt slip.

She took the receipt slip from the document pouch, folded it in half, and tucked it into the fold of this page, pressed flat.

Then, item by item:

July 1st, interview record, original, three pages.

At the word "original," her pen slowed. She could point to the second page, third line with her eyes closed—the place where he'd said "carried" instead of "held," and she'd crossed out the word and rewritten it beside, the fingerprint pressed right next to the correction. At the bottom of each page, in her own handwriting: "The above record has been read to me and matches what I said," with his name after.

Second, one disc.

Her pen stopped here.

Two discs had been burned in July. The one from July 2nd, she'd handed over at the Intermediate Court window, the plastic tray already stacked with papers. The other one sat in the appeal bag under her bed, squeezed in with the petition, the judgment, the release certificate. Except for the trip to the Intermediate Court on July 20th, it had stayed under the bed and never once entered the firm.

She twisted the pen between her fingers. If they left from the firm on the day of the meeting and only remembered at the courthouse gate, the trip would be wasted.

She added a line after this entry: Day of the meeting, leave directly from home.

Next line: Volume Eight, the March 22nd page, to be shown, not submitted, brought back the same day.

When she finished, she capped the pen with a click. The notebook closed and went under the stack of files. Downstairs, the exhaust fan kicked on, ginger and garlic hitting the hot wok with a crackle, and cooking smoke drifted up the stairwell.